TRIBERED OY –  PRIVACY POLICY

Updated 4th January 2018

 

  1. Introduction

Tribered Oy (“Tribered”, “we”, “us” or “our”) is a company registered in Finland, whose registered office is at Erottajankatu 11 B 10, 00130 Helsinki, Finland. We operate this Website and Services available through it (“Services”) as data controller as defined in General Data Protection Regulation (EU 2016/679). In this privacy policy (“Privacy Policy”), references to “you” means any person accessing, downloading or otherwise using our Services. If you have any questions about our data collection practices or this privacy policy, please contact us at contact@tribe.red.

Tribered believes that your privacy is very important and therefore we are committed to protecting and respecting your privacy. We collect, store, use, and manage the information, including personal information, as a data controller in accordance with applicable laws and in order to provide and develop our Services.

Some of the information collected within the Service may be stored on servers located in the United States or in other countries. In this regard, we take steps to ensure adequate safeguards are in place to enable transfer of information outside EU/EEA and the use and disclosure of information about you, including personal information, as described in this Pricacy Policy.

All our Services are governed by this privacy policy (“Privacy Policy”) together with our Terms of Use available at [URL OSOITE] and any other documents referred to in it. By using or accessing a Service you give consent to the processing, use and disclosure of your data. Please do not install, access or use the Services if you do not agree to this Privacy Policy.

We also reserve the right to modify this Privacy Policy. Your continued use of Services will signify your acceptance of the changes to this Privacy Policy.

 

  1. How We Collect Your data

The situations when we collect your data, including Personal Information, include but are not limited to following:

  • Profile information of your social media (SN) account: When you register through SN (such as Facebook-, Google- or through Applen Game Center) you may volunteer information such as profile photo, gender, age or birthday, links to profiles on other social networking websites;
  • Subscribing to our Mailing List: If you subscribe to our mailing list, we will collect you first name, last name and email address;
  • Publicly Shared Information: Data that you share via the Service, such as postings in forums, chats, message boards and blogs, and other interactive features of the Service, your public profile, and your friends list in the Service;
  • Sweepstakes/Promotions: Data that you may provide in order to participate in sweepstakes and promotions. We use this information to notify winners and award prizes, to monitor traffic or personalize the Service.
  • Anonymous game data: As you use our Services, we collect anonymous data about all of your interactions with the Service and other users (such as other players inside the game).
  • When you contact our support: If you contact us, we collect your name and email address. A record of your correspondence with us may also be kept.
  • Employment information: When you apply for a job, you may volunteer information such as resume, name, email address and phone number. We use this information to contact you regarding setting up an interview or to determine if you are qualified for the position in which you applied.
  • General Location data: We collect your location information for the purpose of providing you with the correct version of the application. We collect this information when you start using the Service (i.e when you start playing our game), by looking at the information provided with the connection of the Service on your device.
  • Specific Location data: Please note that in addition to the other information that we collect from you, as defined under this Privacy Policy, we may collect and store information about your location when you use and access specific parts of the Services (i.e. location based games) that utilizes the location services made available through your device’s mobile operating system, which makes use of cell tower triangulation, wifi triangulation, and/or GPS. You understand and agree that by accessing and using those parts of the Services, you will be transmitting your device location to us, and that location will be shared publicly with other users through our Services when you take an in-game action. We may also use location information to improve and personalize our Services for you.

The data we or our third party partners process on you may include, but is not limited to: name, email address and device ID, IP-address. In addition, our outsourcing partners and third party analytics service providers may collect your unique device ID (persistent/non-persistent), hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), IDFA (Identifier For Advertisers), Android ID (Android device), Google Advertiser ID, and network status (WiFi/3G) the version of your operating system (“OS”), application usage data, hardware type, browser information and in-game information, and your device name. This information is used to understand and analyze usage trends. The situations when we and third party service providers collect Personal Information and other data from you is described below in more detail.

  1. Facebook Connect and Inviting Friends

You can log in to our Service using sign-in services (“SN Service“) such as Facebook Connect, Google- or through Applen Game Center. These services will authenticate your identity and provide you the option to share certain Personal Information with us such as your name, email address, and resume to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.

We may collect and record information through the SN Service in accordance with the policies and terms of that SN Service. The information we collect when you connect your user account to an SN Service may include: (1) your name, (2) your SN Service user identification number and/or user name, (3) locale, city, state and country, (4) sex, (5) birth date, (6) email address, (7) profile picture or its URL, and (8) the SN Service user identification numbers for your friends that are also connected to our games. If you want us to delete the data we receive from Facebook please contact us at  contact@tribe.red.

Furthermore, we may offer you the opportunity to invite your contacts from a SN Service (such as your Facebook friends) so that those contacts can be located in our mobile games and/or you can invite them to join you in our mobile games. Such contact information will be used only for the purpose of sending communications to the addressee. You or the third party may contact us at  contact@tribe.red to request the removal of this information from our database to the extent we store any of this information.

 

  1. Ad Networks

We reserve the right to use and disclose the collected, non-personal data for purposes of behaviorally targeted advertising by us or our partners and contractors, such as Localytics, Google and Unity for example.

We may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through Services. These third parties may collect and use data, for such purposes, including but not limited to, data such as IP address, Device ID (persistent/non-persistent), MAC address, installed software, application usage data, hardware type, OS information, browser information, in-game information, IMEI and your device name. The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the third party providing the ad serving technology.

If you wish to “opt out” of targeted advertising, you may contact us at  contact@tribe.red. Please note that if you choose to “opt out” it does not mean that you will no longer receive advertising. It just means that the advertising you see displayed will not be customized to you and your interests and may be less relevant to you.

In addition, you may see our mobile games advertised in other services. After clicking on one of these advertisements and installing our mobile game, you will become a user of our Service. In order to verify the installs, we may have to share a device identifier with the advertiser.

  1. Analytics, tracking and other Collection Practices

Our Own Analytics

Tribered uses your information to perform its own analytics and to enable analytics provided by third parties.  We use analytical information for supporting business analysis and operations, business intelligence, product development, improving products and services, personalizing content, providing advertising, and making recommendations. We use technologies such as cookies, beacons, scripts, and tags to identify your device and to “remember” things about your visit, such as your preferences or a user name and password.  Information stored in a cookie may be linked to your personal information, such as your user ID, for purposes such as improving the quality of our Services, tailoring recommendations to your interests, and making the Service easier to use.  You can disable cookies at any time, although you may not be able to access or use features of the Service.

Third Party Tracking and Analytics

Our Services may contain third party tracking and data collection and analytics tools from our service providers, for example such as Google Analytics. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Site, the Internet Protocol (IP) address, and the type of operating system used in the devices used to access the Site. By using a browser plugin located at http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics from this link https://tools.google.com/dlpage/gaoptout?hl=en.

In addition to Google Analytics, we also use other third party data analytics service providers, such as Gamesparks, Localytics and Unity which help us analyze and improve our Service. The data collected by data analytics service providers enables us to understand usage patterns of the Service. We may permit these service providers to use cookies and other technologies to perform their services for us. Usage information and personal data are stored by such service providers and are subject to their privacy policies. The current list of data analytics service providers we use in connection with the Service can be requested from us at any time by contacting us at contact@tribe.red.

The privacy policies of our service providers may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies.

Other Collection Practices

Our Service includes social media features and widgets, such as the “share this button” or interactive mini-programs that run on our Service. These Features may collect your IP address, which page you are visiting on our Sites, and may set a cookie to enable the Feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing it.

 

  1. Third Party Terms and Conditions

Please note that your access to and use of the Services may be subject to certain third party terms and conditions and Tribered is not liable for any such third parties’ use of your personal data.

Certain Services that Tribered may offer, such as in-app purchases within our games may use third party services to provide authentication for the Services. In connection with such use, certain personally identifiable user information, such as IP address may be transferred automatically to and from Tribered.

Such third parties may also use unique session ID’s, cookies, APIs, and SDKs in our services to enable them to collect and analyze user information on our behalf. The third parties may have access to information such as IP address (including country of origin), App version, device operating system (including version), device make and model, UDID or other unique device identifier (only in anonymized form – i.e., not associated with any other personally identifiable information), and the current time each time you launch our mobile game application for the purpose of providing their services under their respective privacy policies. Our privacy policy does not cover the use of tracking tools from third parties. We do not have access or control over these third parties.

  1. How We May Disclose and Transfer Your Information

Your personal data may be disclosed to third parties including third parties located outside the EU/EEA in accordance with applicable legislation and this Privacy Policy. We may use third parties to collect and process personal data on our behalf and in according to our instructions. Nevertheless, we are not liable for the acts and omissions of these third parties, except as provided by mandatory law.

We may disclose personal data you provide yourself to the Service with the following categories of third parties:

  • Service providers, such as data storage service providers, which enable us to provide the Service to you;
  • Our advertising partners in compliance with applicable laws;
  • Public authorities, such as law enforcement, if we are legally required to so or if we need to protect our rights or the rights of third parties; and
  • Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Policy.

The data collected automatically in the Service may be disclosed to the following categories of third parties:

  • To service providers, such as data analysis companies;
  • To our advertising partners in compliance with applicable laws;
  • To public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
  • To our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Policy.

Moreover, we may disclose information to third parties in an aggregate format that does not constitute personal data and does not allow the identification of individual users.

 

  1. Your rights regarding your personal data

With respect to the personal data relating to you that ends up in our possession, and recognizing that it is your choice to provide us with it, we commit to giving you the ability to do all of the following:

  • Data Requests, Correction, Removal: If you wish to receive a copy, access or correct any personal data we hold about you, or to request that we delete any information about you, you may contact customer service team via the e-mail address or address given below. Your request will be dealt with as soon as possible.
  • Opting out from Commercial Communications: If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided via the e-mail address or address given below.
  • Consent withdrawal or modification: You can withdraw or modify your consent (to the extent you have given such a consent) for collection and processing of the information you provide at any time via the e-mail address, your account details or address given below.
  • Official complaint: You always have the right to lodge a complaint with a supervisory authority in accordance with rules defined in General Data Protection Regulation (EU 2016/679). However, we highly encourage you to work with us in good faith and contact us first.

You may also have choices available to you through the device or software you use to access the Website. For example, the browser you use may provide you with the ability to control cookies or other types of local data storage, or your mobile device may provide you with choices around how and whether location or other data is shared with us.  In particular, if online advertisements are not to your liking, we would encourage you to find out more about the Do Not Track browser setting. To learn more about these choices, please refer to your device or software provider.

If you have any further questions regarding the collection, processing or use of your personal data, please contact us our customer service team at contact@tribe.red. The same applies to information, blocking, deletion and rectification requests regarding your personal data as well as for revocations.

 

  1. Data Security

The security of personal data is important to us. We take reasonable measures to protect personal data about you from unauthorized access or against loss, misuse or alteration by third parties. Despite these efforts to store personal data collected in and through the Service in a secure operating environment that is not available to the public, we cannot guarantee the security of personal data during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of personal data, we cannot guarantee that our security measures will prevent third parties such as so-called hackers from illegally obtaining access to personal data. We do not warrant or represent that personal data about you will be protected against, loss, misuse, or alteration by third parties.

 

  1. Special Note about Children’s Privacy

Tribered does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use our Service. If you are under 13, please do not send any information about yourself to us, including but not limited your name, address, telephone number, or email address. No one under the age of 13 may provide any personal information. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 13, please contact us at contact@tribe.red.

 

  1. Further information

This Privacy Policy is governed by Finnish law excluding its choice of law provisions.

Tribered makes good faith efforts to enable you to review, update or correct your personal data in Tribered’s possession. We will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request.

If you have any questions about this Policy, please contact us at contact@tribe.red.